Healthcare legislation specifies procedures for communicating information within the healthcare industry. For example, Title II (Administrative Simplification provisions) of the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) required the Department of Health and Human Services to establish national standards for electronic health care transactions and national identifiers for providers, health plans, and employers.
On Jan. 1, 2012, an updated version of the healthcare transactions standard, HIPAA 5010, replaced version 4010A1, the current set of standards. Among various changes in this update, HIPAA 5010 mandates changes to the International Classification of Diseases (“ICD”), which is a nomenclature for the classification of diseases, injuries, and other medical conditions. More specifically, HIPAA 5010 requires healthcare payers and providers to transition from the current International Classification of Diseases, 9th Revision, Clinical Modification (“ICD-9”) to a 10th revision (“ICD-10”). This transition is referred to herein as the “ICD-10 migration” and, at present, all healthcare stakeholders (e.g., providers, payers, and employers), must make this transition by Oct. 1, 2015.
ICD-10 codes exhibit fundamental differences as compared with ICD-9 codes. For example, the form and information conveyed in ICD-10 codes is different than that of the ICD-9 codes. More specifically, ICD-9 codes contain three to five digits beginning with either a number or a letter, with a decimal point placed after the third digit, and the ICD-9 book indicates the level of specificity for each code. ICD-10 codes, on the other hand, are seven digits in length. The first three digits of the ICD-10 codes are similar to the ICD-9 codes, with a decimal point after the third digit. However, the digits that follow the decimal point have different, specific meanings. For medical and surgical procedures, for example, the digits that follow are specific to body part, surgical approach, and other qualifiers needed for billing. Similarly, the ICD-10 codes that represent diagnosis codes also have seven digits.
The first three digits of ICD-10 codes are similar to the ICD-9 code, but the additional digits add specificity to the code such as laterality, chronic versus acute, and so on. Another significant difference between the ICD-9 and ICD-10 code sets is the number of codes. More specifically, ICD-9 includes just over 14,000 diagnosis codes and almost 4,000 procedural codes. In contrast, ICD-10 contains over 68,000 diagnosis codes (clinical modification codes) and over 72,000 procedural codes. Due to such fundamental differences, mapping or translation from the ICD-9 code set to the ICD-10 code set presents challenges to ICD-10 migration. For example, while there are some one-to-one correspondences between ICD-9 and ICD-10 codes, there are also one-to-many, many-to-one and many-to-many correspondences and, in some cases, no correspondence at all. Accordingly, ICD-10 migration will undoubtedly affect many aspects of information collection, reporting requirements, billing and payment systems, potentially resulting in benefit, financial and clinical variations.